Nope, that’s your spin. The NHTSA has explicitly stated that there is no requirement for a steering wheel in a self-driving car. However, there are mechanical safety devices that have been traditionally associated with steering wheels that are still required. An example would be the self-cancelling turn signal.
In other words, the NHTSA is saying that while you don’t need a steering wheel, you still need a turn signal that automatically shuts off after the turn is made. This is about the turn signal, not the steering wheel. This is why GM asked for the exemption specifically about the turn signal. The NHTSA was in the process of determining whether what GM did with the turn signal was an acceptable alternative.
To put it another way. If GM had built the Origin with a steering wheel but still without a self-cancelling turn signal, GM would still have had to apply for the same exemption from the NHTSA. This demonstrates that the presence/absence of the steering wheel is irrelevant. This exemption is solely about the self-cancelling turn signal.
This is all made clear in the interaction between Google and the NHTSA linked above. Google asked and asserted the following:
Google further asks that NHTSA “expressly acknowledg[e]” that a steering wheel is not required by the FMVSS. The supplemental information Google provided on January 11, 2016 stated that the SDV’s turn signal operating unit self-cancels based on the position of the steering rack (which is controlled by the SDS), “which is what happens in a conventional vehicle by virtue of the link between the steering rack, steering column, and steering wheel,” and that Google therefore believes that the SDV complies with S9.1.1.
This is the direct response from the NHTSA:
We further agree that a steering wheel is not expressly required by any FMVSS. We agree with Google that, as described, the SDV appears to be designed to self-cancel the turn signal operating unit as NHTSA would have intended, had vehicles without steering wheels been available when FMVSS No. 108 was developed.
Couldn’t be clearer that the NHTSA isn’t concerned about the absence of the steering wheel. It just wanted a turn signal that self-cancelled after the turn. QED
Steering wheels aside, will you at least admit that you have no evidence that a brake pedal is required by the NHTSA in a self-driving car?